Not Doing PQRS? Quick Action Will Avoid a Penalty

UPDATE: On Friday, Oct. 11, 2013, the Centers for Medicare & Medicaid Services announced it is extending the deadline to register from Oct. 15 until Oct. 18 for individual physicians and groups of all sizes. (Note that due to the government shutdown, CMS is unable
to update the Oct. 15 date listed on its website.)

For practices not currently participating in the Medicare Physician
Quality Reporting System (PQRS), another Medicare penalty is looming. Take
action now to sign up to prevent it.

Practices not participating in PQRS in 2013 will pay a 1.5-percent penalty on their Medicare claims in 2015. The Centers for Medicare & Medicaid Services (CMS) has created two options that allow physicians and group practices to still participate in PQRS in 2013 and avoid the penalty — but not be eligible for the PRQS incentive. These two options are for 2013 only.

Administrative claims-based option. To use this option, you must sign up by Oct. 15, 2013. Under this method, physicians or groups can participate in PQRS and avoid the penalty just by signing up — no quality reporting required. But don't delay. Signing up is a multistep process (see below), and practices have reported significant delays in getting their sign-up approved and completed through the Medicare system.

Option to report one individual measure or measure group. This option requires only that the physician or group practice report for 2013 on one measure for one applicable patient or, for individual physicians only, one measures group for at least one applicable patient. Individual physicians may report via claims, registry, or qualified electronic health record (EHR). Group practice may report using a qualified registry or the group practice reporting option Web interface.

If you choose the administrative claims-based option, here's an outline of what you need to do by Oct. 15:

Step 1: Get a new IACS* account or modify an existing account as soon as possible at https://applications.cms.hhs.gov. Individual physicians are identified in IACS by their taxpayer identification number (TIN) and National Provider Identifier (NPI). Groups (defined as two or more eligible professionals) are identified by their TIN. Individuals who bill under the group's TIN do not have to get an IACS account or register for PQRS individually.

If you/your group already has an active IACS account: You must add a PV-PQRS Registration System "role" (i.e., designate a person as PQRS representative) to the account. For help, see the CMS quick-reference guide for individual physicians (PDF) or for group practices (PDF).

If you/your group is creating a new account: You must designate one person to be the IACS account representative and request approval from CMS. This is where the delay is occurring. Once this role is approved, the representative can designate the PQRS representative within IACS (can be the same person).

Step 2: Register in the PV-PQRS Registration System at https://portal.cms.gov using your IACS user ID and password.

Step 3: Choose as your reporting mechanism the administrative claims-based reporting option. Under this temporary reporting mechanism, CMS will automatically analyze all your Medicare claims to find out if you performed a designated set of clinical quality actions (see Tables 123 and 124) over the reporting year. A zero performance rate in any of these actions will not count against you. By signing up for this reporting option so that Medicare can analyze your data, you will not be penalized in 2015 for not participating in PQRS in 2013.

Under the administrative claims-based reporting option, you donot have to submit specific quality data codes for PQRS measures, like you do with traditional PQRS reporting via registry, EHR, or claims.

You will not earn PQRS incentives for reporting through this option; you will only avoid the future penalty.

Additional Options

Physicians and groups can still fully participate in PQRS for 2013 and earn incentive payments, as well as avoid the penalty, by reporting the required measures via claims, registry, or certified EHR. Visit www.cms.gov/PQRS for complete details.

For claims-based reporting, all claims adjustments, reopenings, or appeals processed by Novitas Solutions must reach the national Medicare claims system data warehouse by Feb. 28, 2014, to be included in the 2013 PQRS analysis.

The submission deadline for the PQRSwizard registry is March 13, 2014. For Covisint PQRS, the submission deadline is March 1, 2014. Learn about TMA's discounted rates for these registries.

You have until Feb. 28, 2014, to submit data via a qualified EHR PQRS reporting mechanism. Find out from your EHR vendor if this capability is incorporated into your EHR or is an add-on service.

Group practices of 100 or more eligible professionals also can elect to be subject to a value-based payment modifier under a quality-tiering calculation.

More Information

Find out more on the CMS website about signing up for the CMS-calculated claims option.

For help registering on IACS and the PV-PQRS Registration System, refer to these detailed instructions from CMS. In addition, the CMS QualityNet Help Desk at (866) 288-8912 is open 7 am-7 pm CT, or you can email gnetsuppor@sdps.org. Expect long wait times.

Listen to a short podcast about PQRS 2013 dates from the American College of Physicians.